1. Policy statement
Housing Leeds and Belle Isle Tenant Management Organisation (BITMO) are committed to ensuring that all customers are treated fairly and with respect and can access services and sustain their tenancies. We appreciate that some customers have individual needs which may affect their ability to access services and sustain their tenancy. This policy sets out how we define individual needs, how we identify and record individual needs and how we respond to the needs of our customers to ensure our services are accessible to all customers and that everyone is supported to achieve a sustainable tenancy. It also sets the need for empathy, understanding and respect when dealing with customers with individual needs.
The policy applies to applicants, tenants and members of their household who may also have individual needs, including dependent or grown-up children as well as family and friends of the individual.
2. Aims and objectives of the policy
This policy aims to:
- ensure compliance with statutory and regulatory requirements
- ensure that our services are accessible to all customers
- improve the quality of service that we offer customers
- set out what customers can expect from us as a social landlord
- set out what we expect from our staff and contractors in delivering our services to all our customers
- make efficient use of resources
- support a strengths-based approach which is based on strengthening assets to improve tenancy sustainment and customer satisfaction
This policy does not change, replace, supersede or override statutory provisions, definitions or statutory guidance. It is intended as supplemental to legislation, statutory guidance and case law on housing matters.
3. Legislative context
The following legislation has been considered in developing this policy.
The Public Sector Equality Duty in the Equality Act 2010 requires us to ‘advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it’ but as a social landlord we recognise that tenants may have additional needs for other reasons as well.
The Equality Act also requires us to make reasonable adjustments that ensure relevant disabled customers are not disadvantaged in accessing our services.
The Social Housing Regulator’s Tenant Involvement and Empowerment Standard requires us to treat all tenants with fairness and respect and demonstrate we understand the different needs of tenants, including in relation to the equality strands and tenants with additional support needs. There is a specific expectation that we demonstrate how we respond to those needs in the way they provide services and communicate with tenants.
The Housing Ombudsman Complaint Handling Code states that landlords should comply with the Equality Act 2010 and may need to adapt normal policies, procedures, or processes to accommodate an individual’s needs under a reasonable adjustments policy.
4. Strategic context
This policy links to the following strategic approaches:
- Leeds Ambitions – Healthy, Growing, Thriving, Resilient
- West Yorkshire Housing Strategy: equality and inclusive growth, supporting individuals and communities that face systemic barriers to accessing a safe and stable home
- Leeds Housing Strategy: meeting affordable housing need, improving housing quality, reducing homelessness and rough sleeping, thriving and inclusive communities, improving health through housing, and child and age-friendly housing
- Homelessness and Rough Sleeping Strategy 2023-28: homeless prevention, recovery, shared and integrated approach
- Leeds Domestic Violence and Abuse Strategy
- Leeds Antisocial Behaviour Policy
- Housing Leeds Communication and Engagement Policy
- Leeds City Council’s Safeguarding Policy
- Leeds City Council’s Complaints Policy
5. Definition of individual need
Some customers may face barriers accessing services due to a particular characteristic, illness or life event, and may need us to provide our services in a different way or with an enhancement or additional support to make them accessible. An individual need may be linked to a vulnerability, but equally not everyone with an individual need is vulnerable and so Housing Leeds has taken the decision to develop an individual needs Policy rather than a Vulnerability Policy.
Vulnerability can have specific legal meanings in housing legislation such as in relation to homelessness. Nothing in this policy is intended to change, replace, supersede or override statutory provisions, definitions or statutory guidance in relation to housing matters.
Housing Leeds recognises that customers’ needs can be a changeable state influenced by multiple factors and experiences such as age, bereavement, disability, health issues, mental health, domestic abuse, poverty and personal experiences. Recognising and adapting to these evolving needs is crucial for providing effective support and services.
Some individual needs may be more severe in particular situations, for example in extreme cold or hot weather. Some of the indicators we consider are listed below (indicators may fall into more than one group), but equally not everyone with one of the below indicators will have an individual need (this list is not exhaustive).
Protected characteristics
- Age (older or younger people)
- Carers
- Disability
- Gender reassignment
- Marriage and civil partnership
- Pregnancy and maternity
- Race
- Religion or belief
- Sex
- Sexuality
Health and wellbeing
- Physical or sensory disability
- Neurodiversity
- Dementia
- Learning disability
- Loneliness
- Mental health issues
- Life limiting illness
- Accident or injury
- Substance misuse
- Being a carer
Communications
- English is not their first language
- Unable to read or write
- Visual impairment
- Hearing impairment
Financial
- Financially excluded
- Financial abuse
- Rent arrears or debts
- Employment status
Life events
- Experiencing domestic abuse
- Experience of care or leaving care
- Experience of homelessness/repeat homelessness
- Former armed forces
- Bereavement
- Experienced a crisis or trauma
- Rough sleeping
- Experiencing harassment or ASB
- Relationship breakdown (non-violent)
- Ex-offenders
- Lone parent families
Transition
- Discharge from hospital, prison or other institutional care
- Young person leaving care
- Moving from supported accommodation to independent living
- Moving into first independent property
6. Identifying individual need
It is important that we know the needs of our customers and understand the potential impact that certain characteristics, illnesses or life events can have on an individual’s needs. In identifying individual need, we aim to take a strengths-based approach, and work with individuals to identify how needs can be met in a way which promotes independence.
Every contact with a customer presents an opportunity to identify an individual need which can then be taken into account as part of managing routine service delivery and customer contact.
As part of our strengths based approach we would aim to identify additional needs with the customer’s agreement and consent throughout the lifetime of a tenancy. The main contacts throughout the lifetime of a tenancy include the following:
| Service | How need is identified |
|---|---|
| Housing application form and housing needs assessment | Applicants are asked to provide information about their housing situation and need for rehousing, medical, disability needs, experience of care, service in the armed forces, homelessness, offending, domestic abuse and whether they need support to manage their tenancy. Supporting information may also be provided by third parties, such as support workers, GP's. |
| Housing need and homeless assessments/approaches | Applicants are asked to provide information about their past and current housing and household situations in order to assess their current housing need and to inform necessary statutory decision making. This includes medical, disability needs, experience of care, service in the armed forces, homelessness, offending, domestic abuse and whether they need support to manage their tenancy. Supporting information may also be provided by third parties, such as support workers, GPs. |
| Tenancy offer, viewing, welcome meeting (tenancy sign up) | At the offer, viewing and welcome stage applicants are asked about their up-to-date situation, including identifying any details of individual needs, advocates, support worker, communication needs, interpretation needs, trustees, ability to budget. |
| Home visits | These are in person visits that give tenants the opportunity to meet their Housing Officer and check in on how things are going. We aim to carry out the New Home Visit within 28 days of signing up for a new tenancy to pick up on any issues early in the tenancy. Home Visits are held every 1 to 3 years depending on the level of need. Tenants under 19 or over 75 are flagged for yearly visits. The home visit covers property conditions, rent, support needs and asks if there is anything we can do to improve access to our services. Individual needs alerts are reviewed at home visits. |
| On referral from another agency | When we are contacted by another agency which is connected to the customer to share information about an individual need or barrier to accessing services. This could include Social Care, Police, health or support organisations. |
| Complaints process | Where the complaint raises issues around service provision relating to an individual need. |
| ASB reports and complaints | Where a customer is experiencing ASB which links to a protected characteristic or individual need. |
| Service requests | Where a tenant requests adaptations or equipment to their home or assistance to manage their tenancy or where we receive a request for interpreters, alternative communications such as Braille, large print, BSL. |
| Tenancy issues | Where we are made aware of issues that arise that indicate a potential individual need including: - lack of contact or reports that a home that appears to be abandoned - welfare checks and efforts to locate the tenant will be made - use of property such as suspected tenancy fraud, cuckooing - condition of the garden or property, for example, hoarding - financial – arrears management, right to buy applications - changes in support needs identified through tenant contact/welfare record |
| Repairs, improvements and maintenance | When ordering a repair – additional information is shared by the customer about a need or access arrangements. Where LCC or contractors are unable to gain access to a property for an appointment. Where issues are raised by technical officers or repairs operatives following attendance at a property, for example unacceptable property conditions. Where repeat repairs are raised that indicate a potential individual need such as damage to property or meter tampers. When contacting a customer to discuss investment/planned works. Requests related to disability or individual need where the standard service offer wouldn’t meet needs. |
| Notification of change in tenant circumstances | Death of a joint tenant/household member. Tenant/joint tenant/household member admitted to hospital/care home/prison. Tenancy succession requests. Sole to joint/joint to sole tenancy requests. |
| Tenancy data | Lack of contact about tenancy issues can also be an indicator of an individual need which isn’t being met, including no repairs being reported, no response to correspondence, no access for pre-arranged appointments. |
| Other | Face to face meetings and interviews, emails, annual reviews and surveys. |
7. Recording information
Information about individual needs will be held and processed in line with data protection legislation. Housing Leeds and Belle Isle Tenant Management Organisation (BITMO) will explain the purpose of collecting individual needs information to identify how our service can best respond to the customer’s need.
Housing Leeds seeks to balance the need to record and share information so that the customer isn’t repeatedly asked the same question about their needs while ensuring this information is up to date and shared appropriately to meet their individual needs.
Some information recorded on our housing systems may indicate the customer has individual needs such as disability, age and household make up. Housing application details and tenancy history such as repairs history and rent account may also be an indicator of an individual need.
Where an individual need has been identified it may be appropriate to record it as an alert on housing systems to enable information to be shared and acted on by other services to ensure access to services.
Where appropriate individual needs information will be shared with contractors so that operatives providing services are also able to meet the individual need. Staff should wherever possible discuss with customers how individual needs will be recorded and used to offer reasonable adjustments to services. However, there may be times when the requested adjustments are not feasible, for example, if there is a health and safety hazard such as hoarding in a property.
Individual needs may change over time and so it is important to periodically review a customer’s individual needs to see if there have been changes.
When a reasonable adjustment has been agreed this must be communicated to the customer to make clear how the service will respond to their needs.
8. Ensuring accessibility of routine services
As much as possible we seek to ensure that our services are accessible to all customers including those who have individual needs. As part of our Communication and Engagement Policy we aim to ensure that information shared on our website and in written communications is clear and concise and provides clear information about how to access services and standards of service that a customer can expect to receive.
We also offer a range of opportunities for a customer to access services in order to meet their needs, for example via the tenant portal, telephone, email or in person. Through our routine telephone and face to face customer contact we strive to ensure high levels of customer care and adopt a flexible approach to service delivery in order to ensure that services are accessible to all customers, for example offering a home visit to discuss an issue if a tenant requests this.
9. Reasonable adjustments for disabled customers
Reasonable adjustments are the changes we can make to how we deliver the housing service to ensure disabled customers can access services. When agreeing a reasonable adjustment, we may ask for information or supporting evidence from the customer.
The legal duty making a reasonable adjustment applies to customers who are disabled tenants or where there is a disabled occupier in the property. The reference to disabled is the definition in section 6(1) of the Equality Act 2010.
The council needs to consider reasonable adjustments both as a provider of services/public functions and as a landlord.
Section 6 Disability
(1) A person (P) has a disability if—
(a) P has a physical or mental impairment, and
(b) the impairment has a substantial and long-term adverse effect on P’s ability to carry out normal day-to-day activities.
The duty arises when someone is at a substantial disadvantage compared to people who don’t have a disability because of:
- a rule, practice or way of doing things - the law calls this a ‘provision, criterion or practice
- a physical feature
- not having extra equipment, aids or services - the law calls this an ‘auxiliary aid’
The duty calls for the council to take such steps as are reasonable to avoid the disadvantage or provide the auxiliary aid.
In deciding what reasonable adjustments we can offer we will consider how effective the adjustment will be in overcoming any barriers to accessing the service and how practical it is to make the adjustment. This will include consideration of the cost and practicality of making the adjustment.
Where it isn’t possible to meet a resident’s request for a reasonable adjustment because of the level of additional cost or resource required, or it is impractical to do so we will work with the customer to consider alternatives. If it is not possible to meet a requested adjustment, then the customer should be advised why the requested adjustment cannot be agreed. This is so the customer is clear as to what has or has not been agreed as a reasonable adjustment.
10. Adjustments for customers with other individual needs
Although there is no statutory requirement to consider a reasonable adjustment under the Equality Act for other protected characteristics, the council will consider making adjustments to assist other customers who are not disabled when reasonable and affordable, for example, care leavers, prison leavers. Similar principles will be applied in making a decision to offer an adjustment and informing customers of the decision.
The table below gives some illustrative examples (not solely for reasonable adjustments covered by the DDA but other adjustments that may be considered for customers with individual needs). It is not an exhaustive list and staff are encouraged to consider individual need on a case by case basis:
| Adjustment | Examples |
|---|---|
| Authority to act on behalf of tenant | Contacting via nominated person, Power of Attorney. Booking appointments to include carers and support workers where appropriate and in agreement with the tenant. Authority to act on tenant’s behalf will always be formally arranged and recorded as an alert on the customer’s record. |
| Communication method | Whilst some letters are auto generated and sent to customers, as much as possible we will consider an individual communication need to complement auto generated letters and for other correspondence, for example phone, email, large font for visually impaired customers, alternative/amended letters/email/texts for customers with hearing impairments. Providing translation strapline to all letters sent to customers. Arranging interpreters/translators, Language Line where appropriate to discuss tenancy matters. Making available translations for key documents – Tenancy Agreement. Some communication and contact adjustments will be agreed at the point of contact, others will be agreed for all routine communication and contacts, in which case they will be recorded on the customer’s record. |
| Managing customer contact | Taking more time with a customer for example to read written correspondence/explain how to access a service. Offering in-person/home visits to discuss a tenancy issue/service access request. Offering flexibility around appointment times to avoid certain times of the day which might not meet a customer’s needs. Delaying services due to bereavement, holidays, hospital stays, personal risks or conditions. Allowing more time for a customer to answer the door. Accommodating requests for male/female worker where this can be accommodated. Contacting support workers/social workers when arranging appointments. |
| Responsive repairs | Making an adjustment to the completion of a reported repair, for example access arrangements, repairs priority given, type of repair undertaken. Sharing individual needs alerts with contractors to ensure that repairs operatives can meet individual needs. |
| Tenancy management | Making an adjustment to services provided, for example completion of tenancy visits with an advocate, sign posting for help with maintaining your home and garden, decanting arrangements. |
11. Support to access additional services
As part of every customer contact, we will consider if a customer may benefit from additional support and signpost the customer to access additional services. The table below provides some examples of where we may signpost the customer to additional support services but is not exhaustive. Where possible we will seek to refer with the customer’s consent, but this may not be appropriate in cases of significant harm or severe self-neglect. Additional support needs may become apparent when someone is having difficulties maintaining their tenancy.
| Service | Examples |
|---|---|
| Housing related support/care/mental health/drug and alcohol support | Where a customer has additional support or care needs we will signpost and refer customers to relevant agencies which may provide additional care and support. This can include making a referral with consent to social care for someone to have an assessment of their care and support needs under the Care Act 2014. Where a customer has a Support Worker we will work jointly with the customer and their Support Worker to ensure a collaborative and strengths-based approach to supporting customers to sustain their tenancy. We will record details of a Support Agency and Worker on a customer’s file. Where a customer has complex or multiple needs and doesn’t have support in place we will offer support via our specialist LCC or BITMO Tenancy Support Team who will support a customer to access longer term support. |
| Managing income and arrears | Where a customer needs additional support to maximise their income or apply for housing related benefits to pay their rent/arrears we will offer support to customers to claim benefits or grants, via our Housing Officer Income Team. Where a customer needs support with money and budgeting/debt we can refer customers to Leeds Credit Union/debt advice agencies. |
| Adaptations need | Where a customer needs adaptations or equipment, we can undertake assessments for the completion of adaptations in the home to enable a customer to live independently, including stair lifts, wet floor showers, hearing systems. We can also assess whether a customer’s needs may be better met in a different home and support a customer to consider their options. |
| Retirement life/extra Care | We deliver housing related support to over 4000 customers living in Retirement Life (sheltered housing) schemes through our Service Offer which includes welfare contacts (flexible to customer preferences around method/frequency), regular review of support needs, and signposting, advice and referrals to support customers to live independently in their homes. We also support customers in Extra Care schemes. |
| Digital inclusion | Where a customer is unable to access digital services we will signpost the customer to access digital opportunities and support at the Community Hubs or BITMO’s GATE. |
12. Risk management of individual needs
Sometimes individual needs can increase risk associated with health and safety of the customers, officers, building safety or tenancy sustainment, for example, in a property where items are being hoarded.
We undertake individual need or vulnerability risk assessments as part of our routine service delivery to ensure that risks are considered and used to inform a risk management approach that is proportionate to a customer’s individual needs.
| Service | Examples |
|---|---|
| Fire safety risk management | Where there is an increased risk of fire, we may refer to West Yorkshire Fire and Rescue Service to undertake a Safe and Well Visit, offering information and advice to customers on how to minimise risks. We undertake Person Centred Fire Risk Assessments (PCFRAs) for all council tenants who have an increased fire risk who also live in a high-risk home for example multi story flat. Where a tenant living in a high-risk setting may require support in the event of an evacuation, we review this information as part of our Tenancy Visit Programme and share the information with WYFRS. |
| Tenancy enforcement | We will undertake proportionality assessments before taking action to terminate an Introductory Tenancy or when demoting tenancies to ensure that individual need is taken into consideration. Where a tenant has rent arrears we will consider individual need in accordance with the Pre-Court Protocol – as part of all customer contact to discuss rent arrears and more formally prior to the serving of a notice, issuing possession proceedings and prior to a warrant application. Where individual needs are identified, we will seek to engage with other agencies to ensure that needs are met and consider the proportionality of eviction action prior to progressing possession. |
| Domestic abuse | Where a customer discloses domestic abuse, we will complete a DASH risk checklist to identify risks and liaise with relevant agencies to provide support. Where appropriate will refer to the Sanctuary Scheme for consideration of additional security measures to a customer’s home. |
| ASB | Where there is a report of ASB a THRIVE assessment will be undertaken to assess the threat, harm, risk and vulnerability of the customer(s) involved and inform the proportionality of any actions undertaken, communication and signposting for additional support. |
| Safeguarding including self-neglect | Where a safeguarding risk is identified during a customer contact including self-neglect, we will complete a safeguarding concern record, report the concern to the relevant service and work with the customer and other agencies to try to reduce the risk. |
| Hoarding | Where hoarding is identified during a customer contact, the hoarding risk will be assessed in accordance with the Self Neglect and Hoarding Policy and a referral made to the Housing Officer Support Team or BITMO Tenancy Support Team to offer support to reduce the hoarding risk. |
| Extreme weather | In situations of extreme weather, for example excessive cold or heat we will give consideration to the risks faced by some customer groups and seek to minimize risks through our service delivery, for example making adjustments to repairs response timescales, providing public health guidance to vulnerable groups. |
13. Support and guidance for staff
Everyone in Housing Leeds has a role in ensuring that individual needs are met and it is important that the organisation supports its staff to ensure that they can deliver on its commitment.
Housing Leeds expects staff to consider individual needs as part of all routine service delivery and customer contact.
It is important that staff are aware of different types of individual need and have the skills and confidence needed to have better conversations, adopt a strengths based and trauma informed approach and display professional curiosity. All staff will be trained over the next year to meet the full requirements of this policy.
It is also important that contractors consider customers’ individual needs whilst undertaking services. We will work with contractors over the next year to ensure that operatives are trained on the requirements of this policy and that compliance with the policy is monitored via contract monitoring arrangements.
There are many different statutory organisations, commissioned services and third sector organisations which provide a range of different services to customers with individual needs. Each organisation has different responsibilities, referral criteria and pathways and it can be difficult for Housing staff to determine how best to support a customer to access additional support. We will therefore over the next year look to provide clear guidance to staff on different agencies and referral pathways.
14. Partnership approach
Whilst a key part of this policy is about how Housing Leeds makes reasonable adjustments to its service to ensure that customers with individual needs can access our services, an important focus of the policy is on how Housing Leeds works with a range of specialist service providers to meet individual needs.
We work as part of a number of strategic partnerships relating to the provision of specialist support services, aiming to maximise the effectiveness of the collaborative arrangements ensuring clear referral pathways, communication and measuring demand and outcomes of services. We also work at an operational level to adopt a multi-agency approach on individual case management, working with other agencies to meet wider needs and manage risk, for example through case conferencing.
Housing Leeds is part of a Multi-Agency Working Group facilitated by Leeds Safeguarding Adults Board which is seeking to strengthen a systemic approach to multi agency working for people with self-neglecting behaviours. Once this project has finalised an approach Housing Leeds will look to embed the multi-agency approach as part of its work with customers with individual needs.
External organisations, for example PFI contractors, repairs contractors and internal service providers which provide landlord services to Council and BITMO tenants may have their own Vulnerability or individual needs policies and these organisations and services are requested to support the principles of this policy in their service delivery.
15. Resident engagement
Consultation has been undertaken with partner agencies and tenants and residents asking for their feedback on the principles of this policy. This has been included in the final version of this policy.
16. Communication of the individual needs policy
A summary of the individual needs policy will be shared on our web pages, with a full copy of the policy available. Web pages for individual service areas are currently under review and will outline how we support customers with individual needs to access services where appropriate.
17. Delivering of policy and monitoring of policy outcomes
The Head of Housing and Neighbourhood Services is responsible for overseeing the effective application of the policy and robust management of information on individual needs.
Detailed procedures for the management of individual needs information will be developed and guidance, training will be developed and delivered to support the implementation of this policy.
As part of the routine review of all policies and procedures consideration will be given to individual needs to ensure that this is embedded in all service delivery.
Individual needs information will be subject to quality assurance arrangements to ensure robust data quality.
The success of this policy will be measured by seeing an improvement in performance on the following:
- tenant Satisfaction Measures (TSM) performance by equality characteristics, for example age, disability
- an increase in customer satisfaction from service specific transactional surveys
Progress in the delivery of this policy will be reviewed during the first year and consideration will be given at the end of the first year to determine if changes are required to the policy and the timescale for the next review.
